Please be aware of the following when traveling abroad and forward to any other personnel who may be traveling for this project.
- You should be aware that hardware, software, and various materials, chemicals, microorganisms, and toxins taken with you abroad could constitute an export. Technology should be checked against the Munitions List and the Commerce Control List (Part 774).
- Most laptops and GPS devices (excluding software or technology that contains source code for 64-bit encryption software or mass market encryption products), and cell phones, are considered “tools of the trade” and are frequently carried abroad, but the investigator carrying these devices abroad must keep it on his or her person at all times and make sure the devices are brought back with you. If you plan to leave GPS devices, laptops or mass market encryption products in a foreign country, please inform OSP before you travel. A license from the State Department could be needed before you travel. Software and proprietary data may also be controlled. For more information regarding “tools of the trade”, please refer to the Penn State Export Compliance Manual, pages 47 – 53.
- If project personnel will be providing training to foreign persons (non-students) in the use of ITAR-controlled technology, please inform OSP immediately, because such training could be considered a “defense service.”
- Presentations at international conferences are generally acceptable. It is important to note, however, that sidebar conversations with conference attendees should be limited to information already in the public domain. If the research being discussed in sidebar conversations isn’t related in any way to any technologies on the Munitions List or the Commerce Control List, then there’s no risk of an export of technical data taking place via a sidebar conversation, regardless of where that conversation takes place. But if your research is related to a listed technology, then you can NOT talk to foreign colleagues about your work unless the conversation is licensed or otherwise exempt. Should you have any questions, please contact OSP for further review.
- Please note that Penn State’s policies and guidelines on export compliance in the research environment can be found in RA18 and RAG11.
- The University Office of Risk Management requires prior review of travel to countries under OFAC restriction or where significant concerns for personal safety are involved. Information on the countries requiring prior approval from Risk Management may be found at Risk Management Dangerous Travel Link. If your foreign travel is to any of these locations, your College, Campus or administrative unit must contact Risk Management for prior review and approval of the proposed travel. A copy of Risk Management approval for travel to the countries identified must be provided to OSP in order to close the export review for any such projects. University policies on student international travel may also apply if undergraduate or graduate student foreign travel is included in the project.
- Current travel warnings are provided by the U.S. Department of State. Penn State strongly recommends that you register your trip outside the United States with the U.S. Department of State as a part of the Smart Traveler Enrollment Program (STEP). Registration allows you to record information about your trip so that the Department of State can assist you in case of an emergency. The FBI advises you to make photo copies of your passport and plane tickets and to keep the copies in separate storage. FBI information for traveling overseas with mobile phones, laptops, PDA’s and other electronic devices can be found online.
- All researchers are encouraged to review the OSP Export Compliance Fundamentals website.
- Please let us know if any additional foreign collaborators are added so a denied party screening can be completed. It is important that you include the name of the organization with whom they are associated.